Finding 5535 (2020-004)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2020
Accepted
2023-12-19

AI Summary

  • Core Issue: The Housing Authority lacks a written administrative plan for determining reasonable rent, as required by federal regulations.
  • Impacted Requirements: Compliance with 24 CFR sections 982.54(d)(15) and 982.507 is at risk, potentially leading to unreasonable rent payments.
  • Recommended Follow-Up: The Housing Authority should ensure proper record-keeping by the current vendor and establish a written policy for rent reasonableness determinations.

Finding Text

Criteria: Per 24 CFR section 982.54(d)(15), the Housing Authority must adopt a written administrative plan that establishes local policies for the method of determining that rent paid to an owner is a reasonable rent, initially and during the term of the housing assistance payment contract. Per 24 CFR section 982.507, the Housing Authority must determine that the rent to an owner is reasonable before any subsequent increase in rent is paid to the owner. Condition/Context: We could not determine whether the Housing Authority has a written administrative plan addressing reasonable rent determinations. The Housing Authority was also unable to provide documentation of reasonable rent for the period under audit for tenants. Our sample was not statistically valid. Questioned Costs: Not determinable. Cause: The lack of supporting documentation may be related to the Housing Authority changing voucher program administrators during fiscal year 2020. While the current administrator has access to tenant files, the rent reasonableness procedures performed in fiscal 2020 were done by a previous contractor. Also due to the Housing Authority falling behind on obtaining audits, the documents being requested by auditors are several years old and maybe have been purged. Effect: Rent paid to landlords may not be reasonable in comparison to other comparable unassisted units. Recommendation: The Housing Authority should ensure the vendor administering the program maintains proper records of rent reasonableness. The Housing Authority should also ensure it has a written policy for the method of determining that rent paid to an owner is a reasonable rent as required by 24 CFR section 982.54(d)(15). Views of Responsible Officials: WBHA is concerned that the current contract administrator for the HCV Program has failed to comply with providing the requested documentation as required by 24 CFR section 982.54(d)(15). We are engaging with our current HCV Contract Administrator (Allegiant Property Management, LLC) on expectations for compliance currently and in the future. WBHA is also exploring other contract administrators or possibly opting out of the HCV Program altogether and working with WHEDA to administer WBHA’s HCV Program.

Corrective Action Plan

HCVP Contract Administrator Horizon Management Group informed me in the fall of 2019 that they would no longer be contracting to administer any HCVP effective January 1, 2020. This included WBHA’s program, which they had administered for many years. Prior to January 1, 2020, Horizon Management Group delivered at least 2 dozen boxes of tenant files, inspection files, waiting lists, applications, etc. to WBHA’s office. I was told that these boxes contained all files, current and historic, for our HCVP. We made every effort to administer this program internally with a well-trained, full-time administrative employee who was a Certified Occupancy Specialist with many years of experience at WBHA. She was also trained in HQS Inspections. We also have a full-time Maintenance Supervisor for our properties (Meadowbrook Manor I & II) who is a certified HQS inspector who did conduct inspections for the HCVP post 01/01/2020. The WBHA administrative employee who managed our HCVP from 01/01/20 gave her 2 weeks’ notice to terminate her employment mid-April of 2020 and was gone by the end of that month. I was the only full-time administrative employee during this period. If you recall, businesses began shutting down due to the COVID-19 Pandemic in March 2020. I attempted to secure an HCVP contractor and found Allegiant Property Management to be a good fit for our program. The HCVP files were given to Allegiant Property Management prior to their management of the program which commenced July 1, 2020. That said, Allegiant Property Management was not the HCVP administrator during FYE2019. Efforts to reach out to Horizon Management Group to assist in the audit were not successful. During this same period (November of 2019) I received notice from our usual auditors Tostrud & Temp, LLC. that they would no longer be servicing our geographic area. Finding a new auditor while taking on the administration of the HCVP was a challenge. Adding the timing of our FYE, COVID-19, the unexpected loss of a long-time trusted staff member, hiring and training new staff, etc. was a very challenging situation. Corrective Action Planned: The corrective actions include continuing to work with Baker Tilly to complete our Fiscal Audits to bring our agency up-to-date and compliant. We are continuing to work with Allegiant Property Management to service our HCVP clients. We continue our long professional relationship with the accounting firm, HAB, Inc. WBHA is fully staffed after experiencing more turnover since 2020. I am personally committed to seeing the successful conclusion of these audits and the implementation of any corrective action(s) necessary to continue WBHA’s history as a High-Performing agency. I am also committed to the transparency expected in the administration of publicly funded subsidy programs. Name of Contact Person Responsible for Corrective Action: Melissa Bublitz, Executive Director Anticipated Completion Date: We continuing to work with Baker Tilly to complete our Fiscal Audits to bring our agency up-to-date and compliant. The Housing Authority changed HCVP Contract Administrators effective July 1, 2020.

Categories

HUD Housing Programs

Other Findings in this Audit

  • 5533 2020-002
    Material Weakness Repeat
  • 5534 2020-003
    Material Weakness Repeat
  • 5536 2020-005
    Material Weakness Repeat
  • 581975 2020-002
    Material Weakness Repeat
  • 581976 2020-003
    Material Weakness Repeat
  • 581977 2020-004
    Material Weakness Repeat
  • 581978 2020-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $1.17M
14.182 Section 8 New Construction and Substantial Rehabilitation $358,471